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hold that they are, except for those which respondent has
conceded;
2. whether petitioner is liable for additions to tax for
fraud under section 6653(b)(1) and (2) for 1984 and 1985 and
under section 6653(b)(1)(A) and (B) for 1986 and 1987. We hold
that he is;
3. whether petitioner is liable for additions to tax for
substantial underpayment of tax liability under section 6661 for
1984, 1985, 1986, and 1987. We hold that he is.
Unless otherwise indicated, section references are to the
Internal Revenue Code applicable to the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded to the nearest dollar.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations and the exhibits attached thereto are
incorporated herein by this reference. Petitioner resided in
Ventura, California, when he filed his petition.
Petitioner was the sole proprietor of an insurance agency
and owned residential real estate properties during the years in
issue. For 1984, 1985, and 1986, petitioner prepared his own
Federal tax returns; for 1987, Thomas Proctor, a bookkeeper,
prepared petitioner's return. On the returns, petitioner
reported his receipt of insurance commissions only as reflected
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